APRA CPS 230 · Operational Risk Management

APRA CPS 230 Due Diligence for Material Service Providers

Independent, vendor-neutral due diligence for your material service provider arrangements. CYBORIUM helps APRA-regulated banks, insurers and superannuation licensees evaluate, select and monitor third parties — without commercial bias.

1 July 2025  effective Material  service providers 100%  independent Zero  vendor commissions
Material Service Provider RegisterCPS 230
SERVICE PROVIDER MATERIALITY STATUS Core banking platform Assessed Cloud infrastructure Assessed Payments processor In review Managed security (SOC) In review Offshore BPO Concentration
The obligation

What CPS 230 means for your service provider arrangements

The requirements

What CPS 230 requires for material service providers

Six obligations sit at the centre of the service provider management pillar. Each one needs evidence an auditor and APRA can follow.

01

A register of providers

Maintain a register of material service providers and be able to provide it to APRA on request — kept current as arrangements change.

02

Due diligence before onboarding

Comprehensive assessment before entering into, or materially changing, an arrangement — covering capability, resilience and risk.

03

Ongoing monitoring

Continuous oversight of performance, control effectiveness and risk profile across the life of each material arrangement.

04

Concentration & fourth-party risk

Identify and manage over-reliance on single providers and the sub-contractors (fourth parties) sitting behind them.

05

Contingency & exit plans

Credible, tested plans to substitute or exit a provider without unacceptable disruption to critical operations.

06

APRA notification & board policy

Notify APRA of material arrangements and material risk events, under a service provider management policy approved by the board.

Scope

Who APRA CPS 230 applies to

CPS 230 applies across the APRA-regulated population. If your organisation holds an APRA licence, the service provider obligations apply to your critical third parties.

  • ADIs & banksAuthorised deposit-taking institutions, including foreign bank branches and restricted ADIs.
  • InsurersGeneral insurers, life companies, and private health insurers.
  • Superannuation (RSE) licenseesRegistrable superannuation entity licensees managing members’ retirement savings.
  • Authorised NOHCsNon-operating holding companies within regulated groups.

Timing note: CPS 230 has applied since 1 July 2025. For service provider arrangements in place before that date, APRA’s transitional relief generally allowed compliance by the earlier of the next contract renewal or 1 July 2026. Confirm your entity’s specific obligations with APRA guidance and your own advisers.

3pillars: operational risk, business continuity, service provider management
CPS 231 + 232consolidated and replaced by CPS 230
Criticaloperations define which providers are “material”
Boardaccountable for the service provider management policy
Independentwe sell no products and take no vendor commissions
Evidence-firststructured, documented assessments you can hand to audit
Arm’s lengthselection on merit, not reseller margin
Ongoingmonitoring cadence, not a one-off report
The CYBORIUM role

How independent evaluation supports CPS 230 compliance

CYBORIUM is a vendor-neutral evaluator. We don’t resell technology or earn referral fees, so our assessment of a material service provider reflects fit and risk — the arm’s-length evidence CPS 230 expects.

  • Due-diligence evidenceStructured assessments that document capability, resilience and control maturity before you onboard.
  • Materiality & concentration viewA clear read on which providers are material and where single-supplier concentration builds up.
  • Defensible selectionShortlists and decisions your board and auditors can trace back to objective criteria.
  • Ongoing monitoring inputReassessment on a cadence, so the register stays current as risk changes.

CYBORIUM provides independent sourcing and evaluation support. It does not provide legal or regulatory advice, and does not certify compliance. Your entity remains responsible for meeting its own CPS 230 obligations.

The process

A structured path to defensible third-party decisions

Four steps that turn CPS 230 obligations into repeatable, evidenced practice.

1

Define material services

Map critical operations and set the criteria that make a provider “material” for your entity.

2

Independent due diligence

Assess capability, operational resilience, security and financial standing — on the evidence.

3

Risk & materiality shortlist

Rank options against objective criteria, exposing concentration and fourth-party exposure.

4

Direct engagement & monitoring

You contract directly with the chosen provider, with a reassessment cadence to keep the register current.

The assessment

What we assess in a material service provider

The dimensions that determine whether a third party can be relied on for a critical operation.

Operational resilience

Continuity capability, recovery objectives and the provider’s own dependency chain under stress.

🔒

Information security

Security posture and control maturity, aligned to APRA CPS 234 expectations for information assets.

📈

Financial viability

Financial standing and going-concern signals that speak to a provider’s durability.

🔗

Concentration & fourth parties

Single-supplier reliance and the sub-contractors sitting behind a material provider.

🌎

Geography & data sovereignty

Offshoring, jurisdiction and data-location risk relevant to Australian regulated data.

🔄

Substitutability & exit

How readily the provider can be replaced, and how clean an exit path would be.

The outcome

Audit-ready third-party risk, without the vendor bias

You end up with documented, arm’s-length evidence for every material service provider decision — the kind of trail that stands up to a board, an auditor and APRA.

Start a CPS 230 conversation
EvidenceDocumented due-diligence trail per provider
DefensibleSelection your board can stand behind
LowerConcentration & fourth-party exposure
ZeroVendor commissions or reseller margin
Why independent matters

Arm’s length is the point

CPS 230 is about demonstrable, objective judgement. A reseller earning margin on the provider they recommend can’t offer that. CYBORIUM can — we take no vendor commissions, resell nothing, and have no stake in which provider you choose. Explore our guided vendor evaluations or our framework for enterprise vendor selection.

Questions

APRA CPS 230 third-party risk: FAQ

Under APRA CPS 230, a material service provider is a third party your entity relies on to undertake a critical operation, or one whose failure would expose the entity to material operational risk. These providers must sit on a maintained register, undergo due diligence before onboarding, and be monitored on an ongoing basis.
CPS 230 Operational Risk Management came into effect on 1 July 2025. For service provider arrangements already in place before that date, APRA’s transitional relief generally allowed compliance by the earlier of the next renewal or 1 July 2026.
Yes. CPS 230 consolidates and replaces the former CPS 231 (Outsourcing) and CPS 232 (Business Continuity Management), bringing operational risk, business continuity and the management of service provider arrangements under a single standard.
CPS 230 applies to APRA-regulated entities: authorised deposit-taking institutions (banks), general insurers, life companies, private health insurers, registrable superannuation entity (RSE) licensees, and authorised non-operating holding companies.
Entities must maintain a register of material service providers, perform comprehensive due diligence before onboarding, monitor providers on an ongoing basis, manage concentration and fourth-party risk, hold credible contingency and exit plans, and notify APRA of material arrangements and material risk events — all under a board-approved service provider management policy.
CPS 230 expects arm’s-length, evidenced judgement. Because CYBORIUM sells no products and takes no vendor commissions, our assessments give you objective due-diligence evidence, a clear materiality and concentration view, and defensible selection decisions your board and auditors can trace — without the bias of a reseller earning margin on the provider they recommend.
Book a consultation

Strengthen your CPS 230 third-party due diligence

Talk to an independent evaluator about your material service provider arrangements — no products, no commissions, no bias.

Call 0411 117 108  ·  Mon–Fri 8am–6pm  ·  [email protected]